Interpretation ID: aiam0318
Busby
Rivkin
Sherman and Levy
816 Connecticut Avenue
N.W.
Washington
DC 20006;
Dear Mr. Schwentker: This is in response to your letter of April 20, 1971, in which yo enclosed a request for clarification, on behalf of Rolls-Royce, Ltd., of the requirements of Standard No. 208, Occupant Crash Protection. Essentially, the question was whether a 'European type combined lap and diagonal strap seat belt assembly with retractor' could be furnished instead of the 'Type 1 seatbelt assembly' specified in the second protection option on passenger cars manufactured from August 15, 1973, to August 14, 1975.; Standard No. 208 does not permit this substitution. The key feature o the second option in the August 1973-August 1975 period is that the manufacturer must design his vehicles so that the front seat occupants are protected from injury when restrained with lap belts only, and provide lap belts for all occupants that may, at least, be separately usable as such. A detachable upper torso belt may be provided at the manufacturer's option. The basis for this requirement is the well-documented finding that a much larger percentage of the American public will fasten lap belts than will use upper torso belts, whether the latter are of the detachable or the combination type.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel